ML20154E203
| ML20154E203 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/11/1988 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150E217 | List: |
| References | |
| FOIA-88-198 NUDOCS 8809160255 | |
| Download: ML20154E203 (10) | |
Text
I' THANK YOV.
I WILL ADDRESS 2 DISTINCT AREAS IN MY REMARKS AND RESPONSE TO THE COPNENT.( RECEIVED DURING THE FEBRUARY 18, 1988 MEETING. THESE AREAS ARE EMERGENLf PREPAREDNESS AND ENVIRONMENTAL MONITORING.
I WILL ADDRESS EMERGENCY PREPAREDNESS FIRST.
EMERGENCY PREPAREDNESS RONALD R. BELLAMY, CHIEF FACILITIES RADIOLOGICAL SAFETY AND SAFEGUARDS BRANCH U. S. NUCLEAR REGULATORY COPN!SSION MAY 11, 1988 BEFORE ADDRESSING SPECIFIC CONCERNS RAISED AT THE FEBRUARY MEETING, I'D LIKE TO PROVIDE THE REGULATORY FRAMEWORK FOR EMERGENCY PREPAREDhESS. THE NRC HAS RECOGNIZED THE IMPORTANCE OF EMERGENCY PREPAREDNESS IN PROTECTING THE HEALTH AND SAFETY OF THE PUBLIC AND HAS, OVER THE PAST SEVERAL YEARS, IMPLEMENTED SPECIFIC REGULAf!ONS AND REGULATORY GUIDANCE, SIGNIFICANT INTER-AGENCY COOPERATION, SPECIFICALLY WITH THE FEDERAL EMERGENCY MANAGEMENT AGENCY, HAS RESULTED IN DEFINITIVE CRITERIA BEING PUBLISHED.
I WANT TO ENSURE THAT YOU ARE AWARE OF THESE REGULATIONS AND CRITERI A, AND HOW THE NRC WILL OSE THIS PUBLISHED GUIDANCE IN RESTART DEllBERATIONS FOR THE PILGRIM STATION.
I TITLE 10 0F THE CODE OF FEDERAL REGULATIONS CONTAINS APPENDIX E. ENTITLED "EMERGENCY PLANNING AND PREPAREDNESS FOR PRODUCTION AND UTILIZATION FACILITIES." THIS APPENDIX ESTABLISHES MINIMUM REQUIREMENTS FOR EMERGENCY PLANS FOR USE IN ATTAINING AN ACCEPTABLE STATE OF EMERGENCY PREPAREDNESS.
SPECIFIC REFERENCE IS MADE TO A DOCUMENT DEVELOPED JOINTLY BY THE NRC AND FEDERAL EFERGENCY MANAGEMENT AGENCY, KNOWN AS NUREG-0654, "CRITERI A FOR PREPARATION AND EVALUATION OF RADIOLOGICAL EMERGENCY RESPONSE PLANS AND
- P298n5""25 JOHNSON 88-198 PDR
2 PREPAREDNESS IN SUPPORT OF NUCLEAR POWER PLANTS." THE PLANNING STANDARDS IN NUREG-0654, AS SPECIFICALLY REFERENCED IN THE REGULATIONS, ARE REQUIRED TO BE ADDRESSED IN THE EMERGENCY PLANS.
THESE 16 PLANNING STANDARDS ARE:
A.
ASSIGNMENT OF RESPON3IBILITY (ORGANIZATION CONTROL)
B.
ONSITE EMERGENCY ORGANIZATION C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES D.
EMERGENCY CLASS!FICATION SYSTEM I
E.
NOTIFICATION METHODS AND PROCEDURES t
F.
EMERGENCY CCMMUNICATIONS G.
PUBLIC EDUCATION AND INFORMATION H.
EMERGENCY FACILITY AND E0VIPMENT 1.
ACCIDENT ASSESSMENT J.
PROTECTIVE RESPONSE i
3 4
K.
RADIOLOGICAL EXPOSURE CONTROL L.
MEDICAL AND PUBLIC HEALTH SUPPORT M.
RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS i
t N.
EXERCISES AND DRILLS 0.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING; AND FINALLY P.
RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS 1
I IT IS IMPORTANT TO REAllZ'. THAT THE GOAL OF EMERGENCY PREPAREDNESS IS TO PREPARE ONSITE AND OFFSITE PERSONNEL AND THE PUBLIC, FOR A VARIETY OF WAYS OF DEALING WITH NUCLEAR EMERGENCIES.
IT IS NECESSARY TO BE PREPARED FOR A l
RANGE OF PROTECTIVE ACTIONS.
IT IS NOT APPROPRIATE TO DEVELOP SPECIFIC PLANS 1
FOR EVERY CONCE!VABLE ACCIDENT, BUT TO ACDRESS A SPECTRUM OF ACCIDENTS. TO GIVE FORETHOUGHT TO THF ACTIONS REQUIRED, AND TO KEEP ?N MIND THE OVERALL OB'ECTIVE OF FROVIDING EMERGENCY PLANS, PROCEDURES AND TRAINING TO ACHIEVE DOSE SAVINGS FOR A SPECTRUM OF ACCIDENTS.
ANOTHER SPECIFIC PART OF 10 CFR PART 50 !$ ENTITLED "EMERGENCY PLANS." AND TF!S 1510 CFR 50.47. THIS REGULATION IDENTIFIES THE NRC AS THE REGULATORY AUTHORITY THAT 15 REQUIRED TO MAKE A FINDING ON EMERGENCY PREPARECNESS PRIOR TO THE ISSUANCE OF AN OPERATING LICENSE FOR A NUCLEAR F0WER RE ACTCR, THE i
4 REQUIRED FINDING IS THAT "THERE IS REASONABLE ASSURANCE THAT ADEQUATE PROTECTIVE MEASURES CAN AND WILL BE TAKEN IN THE EVENT OF A RADIOLOGICAL EMERGENCY. " THE NRC, HOWEVER, DOES NOT OBTAIN INFORMATION TO MAKE THIS CONCLUSION IN A VACUUM. WE CONSIDER, FIRST. THE REVIEW OF FEDERAL EMERGENCY MANAGEMENT AGENCY, AND THAT AGENCY'S FIN 0!NGS AS TO WHETHER STATE AND LOCAL PLANS ARE ADEQUAYE, SECOND, WHETHER THERE IS A REASONABLE ASSURANCE THAT THEY CAN BE IMPLEMENTED, AND THIRD, THE NRC ASSESSHENT AS TO WHETHER THE APPLICANT'S ONSITE EMERGENCY PLANS ARE ADEQUATE AND WHETHER THEY CAN BE IMPLEMENTED.
THE ULTIMATE DECISION AS TO WHETHER THE STATE OF EMERGENCY PREPAREDNESS IS ADEQUATE TO PROTECT PUBLIC HEALTH AND SAFETY RESTS WITH THE NRC.
AT 7E PUBLIC MEETING HELD FEBRUARY 18, 1988, THERE WAS A CONCERN WITH THE NRC REi:EW PROCESS, AND ITS BASES, FOR EMERGENCY PREPAREDNESS. I HAVE ADDRESSED GENERALLY THE CRITERIA FOR THIS REVIEW.
ONE SPECIFIC CONCERN DEALT WITH THE EMERGENCY ACTION LEVELS.
NUREG-06S4 SPECIFIES THESE EMERGENCY ACTION LEVELS IN INCREASING LEVEL OF SIGNIFICANCY AND REQUIRED (CTIONS, AS 1.
NOTIFICATION OF UNUSUAL EVENT I
2.
ALERT 3.
SITE AREA EMERGENCY 3
4.
GENERAL EMERGENCY I
A G3ADATION 15 PROVIC;D TO ASSURE FULLER RESPONSE PREPARATIONS FOR HORE SERIOUS INC : C ATOR$.
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_.......s_....
1 5
TO GIVE YOU A BETTER UNDERSTANDING OF THESE CLASSES:
1.
FOR A NOTIFICATION OF UNUSUAL EVENT THE LOWEST OF THE EVENT CLASS!FICATION, UNUSUAL EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL 0F SAFETY OF THE PLANT.
NO RELEASES OF RADIOACTIVE MATER'AL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.
I PERSONNEL ARE BROUGHT TO A STATE OF READINESS, PREPARED FOR ANY FURTHER RESPONSE. RELATIVELY MINOR EVENTS CAUSE THE DECLARATION OF 1
AN UNUSUAL EVENT, SUCH AS THE TRANSPORTATION OF A CCNTAMINATED j
INJURED INDIVIDUAL FROM THE SITE TO AN OFFSITE HOSPITAL, OR REACTOR j
COOLANT TEMPERATURES OR PRESSURE OUTSIDE EXPECTED VALUES.
2.
FOR AN ALERT, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF l
SAFETY OF THE PLANT.
ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PROTECTIV: ACTION GUIDELINES. THIS SECOND STAGE EMERGENC) ACTION LEVEL WOULD BE DECLARED IF HVRRICANE WlhDS WERE PRESENT NEAR THE SITE, OR RADIOLOGICAL EFFLUENTS WERE 10 TIMIS GREATER THAN ALLOWABLE INSTANTANEOUS LIMITS, 1
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6 3.
FOR A SITE AREA EMERGENCY, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE ACTUAL OR LIKELY MAJOR FAILURES OF SYSTEMS OR EQUIPMENT NEEDED FOR PROTECTION OF THE PUBLIC. ANY RELEASES ARE NOT EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINES EXCEPT NEAR THE SITE BOUNDARY. A STEAM LINE BREAK OUTSIDE CONTAINMENT, WITHOUT BEING ISOLATED, OR SEVERE DAMAGE TO SAFE SHUTDOWN EQUIPMENT FROM MISSILES OR EXPLOS!ONS ARE EXAMPLES OF SITE AREA EMERGENCIES.
f 4.
FOR A GENERAL EMERGENCY, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INYOLVE ACTUAL OR IMMINENT SUBSTANTIAL CORE DEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OF CONTAlhMENT INTEGRITY. RELEASES d
i CAN BE REASONABLY EXPECTED TO EXCEED EPA PR0fECTIVE ACTION GUIDELINES OFFSITE FOR MORE THAN THE IMMEDIATE SITE AREA. A GENERAL EMERGENCY WOULD BE DECLARED IF A LOSS OF 0FFSITE POWER OCCURS PLUS FAILURE OF REACTOR SHUTDOWN SYSTEMS, OR EFFLUENT MON! TOR DETECT
$1GNIFICANT RADIATION LEVELS AT THE $1TE BOUNDARY UNDER ACTUAL METEOROLOGICAL CONDITIONS.
t BOSTON EDISON 15 REQUIRED TO, AND HAS BEEN CONDUCTING TRAINING, ON HOW VARIOUS PLANT EVENTS LEAD TO THE DECL/PA '!ON OF THESE EMERGENCi ACTIONl.EVELS. THE hRC Will. INSPECT THIS Akti, AND ENSURE THAT l
PLANT OPERATION CAN APPROFRIATElY CATEGORIZE PLANT EVEhTS.
A SECOND SPECIFIC CONCERN P.AISED DURihG THE EARLIER PUBLIC HEET!hG DEALT WITH ALERT AND NOTIFICATION OF THE PUBLIC. APPENDIX E. REFERENCED EARLIER, STATES ThAT PUBLIC ENERGENCY FREPAREDNESS PLANNING INFORMATION SHALL BE GIVEN TO
7 PUBLIC WITHIN THE 10 MILE ON AN ANNUAL BASIS.
THIS INFORMTION SHALL INCLUDE NETHODS AND TIMES REQUIRED FOR PUBLIC NOTIFICATION AND THE PROTECTIVE ACTIONS PLANNED IF AN ACCIDENT OCCURS, GENERAL INFORMATION AS TO THE NATURE AND EFFECTS OF MDIATION, AND A LISTING OF LOCAL BROADCAST STAT!0NS THAT WILL BE USED FOR DISSEMINATION OF INFORMATION DURING AN EMERGENCY. WE ARE AWARE THAT THis IMr0RMATION HAS NCT BEEN DISTRIBUTED FOR THE PILGRIM STATION FOR 1987 OR DU21NG 1988, AND THAT THE COMMONWEALTH OF MASSACHUSETTS HAS DETERMINED !T IS hCT APPROPRIATE TO DISTRIBUTE EMERGENCY PREPAREDNESS INFORMATION UNTIL CHANGES TC THE APPROFRIATE EMERGENCY PLANS ARE COMPLETED.
THE NRC WILL YERIFY THAT TNIS PUBLIC INFORMATION IS AVAILABLE PRIOR TO RESTART OF THE PILGRIM STATION.
)
AIDITICNALLY, A PROMPT PUBLIC NOTIFICATION SYSTEM SHALL HAVE A DESIGN i
CE.ECTIVE OF BE!NG CAPABLE OF ESSENTIALLY COMPLETING THE lh!TIAL NOT!FICATION j
OF BE PUBLIC WITHIN THE 10 MILE EP2 WITHIN ABCUT 15 MINUTES.
THE USE OF THIS hC'!FICATION CAPABILITY WILL RANGE FROM 1*EDIATE NOT!FICAi!0N OF THE PUBLIC (h:'NIN 15 MihUTES OF THE TIME THAT STATE AND LOCAL OFFICIALS ARE NOTIFIED THAT 1
i A SITUATION E!!STS REQUIRING URGENT ACTION) TO THE MORE LIKELY EVENT 3 WHERE TPIRE IS SUBSTANTIAL T!ME AVAlt.ABLE FOR THE STATE AND 1.0 CAL GOVERNMENTAL OFFICIALS l
J TC MAKE A JUDGEMEhT WHETHER OR NOT TO ACTIVATE THE PUBLIC h0TIFICATION SYSTEM.
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h> IRE THERE IS A DECISION TO ACTIVATE THE NOTIFICATION SYSTEM, THE STATE AND i
LC'.AL OFFICIALS WILL DETERM!hE WHETHER TO ACTIVATE THE ENTlRE h0TIFICATION l
$*5 EM SIMULTANECUSLY OR IN A GPADUATED OR STAdED MANNER. THE RESPCNSIBILITY l
FC: ACT!VATING SUCH A PUBLIC NOT!FICATION SYSTEM SHALL REMA:N WITH THE U:: CPRIATE GOVERhMENTAL AUTHORITIES. NUREG-0654 INDICATE! THAT THE DESIGN i
8 03JECTIVE DISCUSSED A80VE REASONABLE ASSURANCE THAT EARLY NOTIFICATION CAN BE i
PROVIDED. PERIDOIC TESTING OF SIRENS IDENT!FIES DEFICIENCIES IN THE SYSTEM, AND LOCALITIES WHERE IMPROVEMENTS ARE NECESSARY.
i EMERGENCY PLANS ARE DOCUMENTS THAT ARE CONSTANTLY UNDERG0ING CHANGES AND REVISION. TPE OFFS!TE EMERGENCY PREPAREDNESS PLANS FOR PILGRIM STATION WERE 1
SUBMITTED BY THE MASSACHUSETTS CIVIL DEFENSE AGENCY TO FEMA IN 1981. NUMEROUS
)
DRILLS AND Full-SCALE EXERCISES WERE HELD AS REQUIRED, WITH APPROPRIATE STATE r
j AND LOCAL PARTICIPATION. HOWEVER, DUE TO DEFICIENCIES IDDiTIFIED DURING THESE DRILLS AND EXERCISES, AND A LACK OF PROGRESS BY OFF-SITE ORGANIZATIONS (STATE ANC LOCAL COMMUNITIES) IN CORRECTION CF LONG-STANDING PLAN DEFICIENCIES, l
FEDERAL EMERGENCY KANAGEMENT AGENCY CONDUCTED A SELF-! NIT!ATED REVIEW OF PILGRIM, AND PUBLISHED THEIR REPORT ON AUGUST 4,1987.
FEMA REVIEW INCLUDED THE REPORT ISSUED BY MASSACHUSETTS SECRETARY OF PUBLIC SAFETY, CHARLES BARRY, IN DECEMBER 1986. FEMA IDENTIFIED SIX ISSUES.
THESE ARE 1
LACK OF EVACUATION PLANS FOR SOME PUBLIC AND PRIVATE SCHOOLS AND DAY CA L
i j
CENTERS.
t f
LACK OF A RECEPTION CENTER FOR PEOFLE EVACUATING TO THE NORTH.
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LACK OF IDENTIFIABLE PUBLIC SHELTERS FOR THE BEACH POPULATION.
a INADEQUATE PLANNINO FOR SPECIAL NEEDS POPULATION.
}
1 i
9 INADEQUATE PLANNING FOR THE EVACUATION OF THE TRANSPORTATION DEPENDENT POPULAT10N.
OVERALL LACK OF PROGRESS IN PLANNING AND APPARENT DIMINUTION OF EMERGENCY PREPAREDNESS.
THE NRC TRANSMITTED THE REPORT AND THESE FINDINGS TO THE BOSTON EDISON COMPANY IN AUGUST 1987 ENCOURAGING BOSTON EDISON ') WORK WITH, AND SUPPORT, THE C06NONWEALTH OF MASSACHUSETTS AND LOCAL ORGANIZATIONS TO CORRECT THE DEFICIENCIES. WE ARE AWARE OF SOME OF THE WORK TO DATE IN IMPROVING THE OFFSITE EMERGENCY PREPAREDNESS PROGRAMS AT PILGRIM AND COP.lCTING THE EMERGENCY PLANNING DEFICIENCIES IDENTIFIED BY FEDERAL EMERGENCY MANAGEMENT AGENCY. WE ARE AWARE THAT ORAFTS OF THE LOCAL EMERGENCY PLANS HAVE BEEN COMPLETED AND THAT THESE PLANS HAVE BEEN FORWARDED BY THE COMMONWEALTH TO FEDERAL EHERGENCY MANAGEMENT AGENCY FOR TECHNICAL REVIEW.
THIS INITIAL TECHNICAL REVIEW HAS BEEN CCPPLETED, AND FEDERAL EMERGENCY MANAGEMENT AGENCY HAS TRANSMITTED COMMENTS BACA TO THE COMMONWEALTH. IDENTIFYING AREAS WHERE FURTHER WORK IS REQUIRED. kE ARE AWARE THAT THE DRAFT MASSACHUSETTS civil DEFENSE AGENCY AREA 11 PLAN IS ESSENTIALLY COMPLETE AND IS BE!NG REVIEWED BY i
THE COMONWEALTH, AND THE DRAFT OF THE COMMONWEALTH PLAN FOR PILGRIM 15 NEARING COMPLETION.
NRC HAS STATED AT SEVERAL PUSLIC MEETINGS THAT IT WILL NOT PERMIT THE PILGRIM FACILITY TO RESUPE CFERATICL UNTil CORRECTIVE ACTION SATISFACTORY TO NRC HAVE
{
BEEN TAKEN TO ADDRESS THE EPERGENCY PLAhh!NG DEFICIENCIES IDENTIFIED BY j
e 10 FEDERAL EMERGENCY MNAGEMENT AGENCY.
THE NRC WILL GIVE SPECIAL ATTENTION TO THE SCHOOLS AND DAY-CARE CENTERS, AS WELL AS FOR SPECIAL NEEDS AND TRANSPORT-DEPENDENT POPULATIONS IN THE PLUME EXPOSURE PATHWAY EPZ. BEF ALLOWING PILGRIM TO RESTART, THE NRC NILL REQUIRE SOME DEMONSTRATION THAT CRITICAL ASPECTS OF THE EMERGENCY PLAN CAN BE ADEQUATELY IMPLEMENTED.
THE NRC MAY AUTHORIZE RESTART WITH SOME PLANNING ISSUES NOT FULLY LONG AS THE NRC CAN STILL MAKE A FINDING THAT THERE IS REASONABLE ASSURA THAT THE PUBLIC HEALTH AND SAFETY CAN BE PROTECTED.
IN REACHING THIS DEC'.SION, THE NRC WILL EXAMINE EACH PLANNING DEFICIENCY '.ND WElGH THE SIGNIFICANCE THE DEFICIENCY, THE hATURE OF ANY COMPENSATOFI ACTIONS, AND THE PROGRESS BEING MADE BY THE CCMMONWEALTH, LOCAL GOVERNMENTS AND THE LICENSEE TOWARD CORRECTION i
0F THE DEFICIENCY. EMERGENCY PLA'iNING IS A DYNAMIC PROCESS AT OPERA PLANT SITES IN THE UNITED STATES.
IN >RACTICE WE EXPECT THAT EMERGENCY
)
RESPONSE PLANS WILL EE REY! SED AND IMPROVED ON A CONTINUAL BASIS. D IDENTIFIED btRING THE ONGOING REVIEk' PROCESS AND IN BIENNIAL EXERCISES i
0F THESE SITES ARE ASSESSED FOR SICN!FICANCE AND THE REGULATION PERMIT PLANTS MAY BE ALLOWED TO OPERATE WHILE THE DEFICIEhCIES ARE BEING. C GIVEN THE PROGRESS 10 DATE AT PILGRIM, IT IS PREMATURE AT THIS TIME TO ATTEMPT t
TO DETERMINE WHICH, if ANY DEFICIENCIES HAY REMAIN WHEN RESTART DECISIONS ARE l
TO BE MADE.
IN CONCLUSION THE hRC 15 AWARE OF THE IDENT!f!ED DEFICIENC!ES IS OFFSITE l
EMERGENu P.*hNihG AiOUND P!LGRIP, AND THE CORRECTIVE ACTION UNDERWAY.
THE NRC WILL NOT PERHli PILGFIM TO RESUME OPERATIONS l'NTIL CORRECT!YE ACTION TORY TO THE NRC HAS lEEN TAKEN TO AEDRESS THESE EMERGENCY PLAN
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